Breaker

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Transparency

Does the policy require users to be notified in case of a data breach? No

0/7

Decided May 19, 2020 (revision history). This question accounts for 8% of the final score.

Note that all companies operating in the EU are subject to Art. 33 of the GDPR, which requires companies to notify their data protection authority of a data breach within 72 hours of discovering it.

Possible Options

No0/7
Yes, eventually5/7
Yes, within 72 hours7/7
N/A (the service collects so little personal data that notification would not be possible)7/7

Note

The service's policy doesn't require users to be disclosed to breaches

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Will affected users be notified when the policy is meaningfully changed? Yes

5/5

Decided May 19, 2020 (revision history). This question accounts for 6% of the final score.

Possible Options

No0/5
Yes5/5
N/A (no personal data—or contact information—collected)5/5

Citation

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

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Is the policy's history made available? Only the date it was last modified

3/5

Decided May 19, 2020 (revision history). This question accounts for 6% of the final score.

Possible Options

No0/5
Only the date it was last modified3/5
Yes, with revisions or a change-log5/5

Citation

Latest update: February 14, 2019

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Does the policy outline the service's general security practices? Somewhat

1/3

Decided May 19, 2020 (revision history). This question accounts for 4% of the final score.

The policy provides only a very vague overview of its security practices.

Possible Options

No0/3
Somewhat1/3
Yes2/3
Yes, including audits2.5/3
N/A (no personal data collected)3/3
Yes, including independent audits3/3

Citation

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

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Collection

Is it clear why the service collects the personal data that it does? Somewhat

4/10

Decided May 19, 2020 (revision history). This question accounts for 12% of the final score.

This question deals with transparency. Even if the service uses data for reasons that aren't ideal for privacy, provided they list all of those uses, the service can still receive full credit for this question. However, if they are not explicit about their uses (by employing language like "such as"), a lower score is assigned.

Possible Options

No0/10
Somewhat4/10
Mostly7/10
Yes10/10
No personal data is collected10/10

Citation

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Access to third party accounts, Registration and authentication, Analytics, Infrastructure monitoring, Managing contacts and sending messages and Handling payments.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

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Does the policy list the personal data it collects? Yes, generally

7/10

Decided May 19, 2020 (revision history). This question accounts for 12% of the final score.

All general categories of collected personal data are listed, though not all types of personal data are explicitly mentioned (for example, the list might use a phrase like 'such as' when listing types of personal data).

Possible Options

No0/10
Only summarily3/10
Yes, generally7/10
Yes, exhaustively10/10
N/A (no personal information is collected)10/10

Citation

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application. Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

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Does the service collect personal data from third parties? Yes

0/10

Decided May 19, 2020 (revision history). This question accounts for 12% of the final score.

This includes the use of data brokers and independent verification authorities (such as background check providers).

Possible Options

Yes0/10
Only for critical data7/10
No10/10

Citation

Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.

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Does the service allow the user to control whether personal data is used or collected for non-critical purposes? On an opt-out basis, for all non-critical data/uses

3/5

Decided May 19, 2020 (revision history). This question accounts for 6% of the final score.

Some services allow users to opt-out or opt-in to of non-critical collection or use of personal data, such as collecting data for personalized advertisements.

Possible Options

No0/5
On an opt-out basis, but only for some non-critical data/uses1.5/5
On an opt-out basis, for all non-critical data/uses3/5
N/A (no data used for non-critical purposes)5/5
On an opt-in basis5/5

Citation

MixPanel is an analytics service provided by Mixpanel Inc. Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy. Privacy Shield participant.

Branch Attribution is an analytics service provided by Branch Metrics, Inc. Personal Data collected: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy – Opt Out .

Crashlytics is a monitoring service provided by Google Inc. Personal Data collected: geographic position; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

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Handling

Does the policy allow personally-targeted or behavioral marketing? Yes, but you can opt-out

3.5/10

Decided May 19, 2020 (revision history). This question accounts for 12% of the final score.

Possible Options

Yes0/10
Yes, but you can opt-out3.5/10
Yes, but you must opt-in7/10
No10/10

Citation

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); [...] MixPanel is an analytics service provided by Mixpanel Inc. Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy. Privacy Shield participant.

Branch Attribution is an analytics service provided by Branch Metrics, Inc. Place of processing: United States – Privacy Policy – Opt Out .

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Does the service allow third-party access to private personal data? Yes, all parties specified (including non-critical service providers such as advertisers)

3/10

Decided May 19, 2020 (revision history). This question accounts for 12% of the final score.

This may come in the form of outright data sharing or by using local third-party analytics software (such as Google Analytics, which collects a plethora of user information).

Note that whether the policy allows sharing aggregated user data does not affect this question.

If the personal data is encrypted when it passes through the third-party, it does not count as third-party access (as the data is inaccessible to that party).

If personal data has been made public by, for example, posting it to a blog, it does not count as private personal information (and is therefore not considered by this question).

Possible Options

Yes, not all parties specified0/10
Yes, all parties specified (including non-critical service providers such as advertisers)3/10
Yes, not all parties specified (but only to critical service providers)7/10
Yes, all parties specified (only to critical service providers)8/10
No10/10

Citation

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); geographic position; email address; various types of Data; first name; last name; gender; date of birth; phone number; address; country; profession.

[...]

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

MixPanel (MixPanel) MixPanel is an analytics service provided by Mixpanel Inc. Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

Google Analytics Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy. Privacy Shield participant.

Branch Attribution (Branch Metrics, Inc.) Branch Attribution is an analytics service provided by Branch Metrics, Inc. Personal Data collected: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy – Opt Out .

Payment processing services enable this Application to process payments by credit card, bank transfer or other means. To ensure greater security, this Application shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction. Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

Stripe (Stripe Inc) Stripe is a payment service provided by Stripe Inc. Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

This type of service allows this Application to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved. Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application.

Crashlytics (Google Inc.) Crashlytics is a monitoring service provided by Google Inc. Personal Data collected: geographic position; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Mailgun (Mailgun, Inc.) Mailgun is an email address management and message sending service provided by Mailgun, Inc. Personal Data collected: address; Cookies; country; date of birth; email address; first name; gender; last name; phone number; profession; Usage Data; various types of Data.

Place of processing: United States – Privacy Policy.

By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third party services, for registration or identification purposes.

Twitter OAuth (Twitter, Inc.) Twitter Oauth is a registration and authentication service provided by Twitter, Inc. and is connected to the Twitter social network. Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: US – Privacy Policy.

Facebook Authentication (Facebook, Inc.) Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network. Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: US – Privacy Policy.

Stripe OAuth (Stripe Inc) Stripe OAuth is a registration and authentication service provided by Stripe, Inc. and is connected to the Stripe network. Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

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Does the service allow you to permanently delete your personal data? Yes, by contacting someone

3/5

Decided May 19, 2020 (revision history). This question accounts for 6% of the final score.

Even if there is a reasonable delay before the data is fully deleted (as is common), the data still counts as "permanently deleted" and satisfies the parameters for this question.

Possible Options

No0/5
Yes, by contacting someone3/5
Yes, using an automated mechanism5/5
N/A (no personal information collected)5/5

Citation

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

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When does the policy allow law enforcement access to personal data? When reasonably requested

3/5

Decided May 19, 2020 (revision history). This question accounts for 6% of the final score.

Possible Options

Always0/5
Not specified0/5
When reasonably requested3/5
Only when required by a court order or subpoena4/5
N/A (no personal data to share)5/5
Never (special legal jurisdiction)5/5

Citation

processing is necessary for compliance with a legal obligation to which the Owner is subject;

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Warnings

Breaker has no warnings published on PrivacySpy. PrivacySpy publishes warnings when it learns a service has announced a data breach or is found misusing user data. If you believe a warning should be published for Breaker, submit one here.


Highlighted Policy Snapshot ALPHA

No highlighted policy snapshot has been created for this privacy policy. To view the policy at its original location, click here.

4.2/10

How we calculate ratings →


Version Added

May 19, 2020

Ratings Updated

May 19, 2020

Warnings

0

Maintained by

doamatto

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